Privacy Policy - Worldwide

Last updated: November 20, 2017

Welcome to Hydrogen!

Privacy and online safety are important
to The Hydrogen Technology Corporation (“Hydrogen”). We offer a software
platform and services for helping developers and enterprises build and run fintech businesses around the globe. Some of our products
and services are available for free without registering as a user on our site;
other products and services require registering as a user on our system; other
products and services may involve certain fees. Please also reference our Terms of Use for more information on your
rights as a Hydrogen user.

We collect data about businesses and
their customers (“Data”) when they use the platform, the
services, and our websites (collectively, “Services”). This privacy policy describes how we
collect, use and disclose Data.

In this privacy policy, we sometimes
refer to “You”. “You” may be a visitor to one of our websites, a user of one or more
of our Services (“User”), or a customer of a User (“Customer”). We’ll do our best to clarify who we are referring to at various points in the policy.
This policy does not apply to third-party websites, products, or services even
if they link to our Services, and You should consider
the privacy practices of those third-parties carefully. If You
disagree with the practices described in this policy, You should (a) take the
necessary steps to remove cookies from Your computer after leaving our website,
and (b) discontinue Your use of our Services.

1. Overview

The Data we collect depends on how our
Services are used. Sometimes we receive Data directly, such as when a Hydrogen
account is created, test transactions are submitted through our website, the
Hydrogen Sandbox is used, or we receive an email. Other times, we get Data by
recording interactions with our Services – for example, using
technologies like cookies and web beacons. We also get Data from third parties,
like our financial partners or identity verification services.

The collection and use of data from a
variety of sources is essential to our ability to provide our Services –
and to help keep the Services safe. Data is critical in helping us to increase
the safety of Your online payments, and reduce the
risk of fraud, money laundering and other harmful activity.

2. Data We Collect

a. Personal
Data. We call
Data that identifies, or that could reasonably be used to identify, You as an individual “Personal
Data”. We collect
Personal Data in different ways. For example, we collect Personal Data when a Developer
or Enterprise registers for a Hydrogen account (“User”), a Customer interacts
with a User’s website or application, a person responds to Hydrogen emails or
surveys. We also receive Personal Data from other sources, such as our
partners, financial service providers, identity verification services, and
publicly available sources. Personal Data does not include Data that has been
aggregated or made anonymous such that it can no longer be reasonably
associated with a specific person. The Personal Data that we may collect
includes:

·Financial and transaction Data, such as credit or debit
card number, and bank account information; and

·Other Personal Data, such as date of birth, SSN or EIN.

b. Other
Data. We call
Data other than Personal Data “Other Data”. We collect Other Data through a
variety of sources. One of our sources for Other Data is cookies and other
technologies that record Data about the use of our websites, websites that
implement our Services, and the use of our Services generally. Other Data that
we may collect include:

·Browser and device data, such as IP address,
device type, operating system and Internet browser type, screen resolution,
operating system name and version, device manufacturer and model, language,
plug-ins, add-ons and the version of the Services You are using;

·Transaction data, such as purchases, purchase amount, date of purchase,
and payment method;

·Cookie and tracking technology data, such as time spent on
the Services, pages visited, language preferences, and other anonymous traffic
data; and

3. How We Use Data

a. Personal
Data.We and our service providers use Personal Data to: (i) provide the Services; (ii) detect and prevent fraud;
(iii) mitigate financial loss or other harm to Users, Customers, and Hydrogen;
and (iv) promote, analyze and improve our products, systems, and tools.
Examples of how we may use Personal Data include:

·To verify an identity for
compliance purposes;

·To evaluate an
application to use our Services;

·To conduct manual or
systematic monitoring for fraud and other harmful activity;

·To conduct aggregate
analysis and develop business intelligence that enables us to operate, protect,
make informed decisions, and report on the performance of, our business.

b. Other
Data. We may
use Other Data for a range of different purposes, provided we comply with
applicable law and our contractual commitments. In some countries (for example,
European Economic Area countries), local legal regimes may require us to treat
some or all of Other Data as “personal data” under applicable data protection
laws. Where this is the case, we will process Other Data only for the same
purposes as Personal Data under this privacy policy.

4. How We Disclose Data.

Hydrogen does not sell or rent Personal
Data to marketers or unaffiliated third parties. We share Your Personal Data
with trusted third parties, including:

a. To Hydrogen
Affiliates. We
share Data with entities worldwide that we control, are controlled by us, or
are under our common control, to provide our Services. The Hydrogen Technology
Corporation is the party responsible for overall management and use of the Data
by these affiliated parties;

b. To Hydrogen
Service Providers. We
share Data with service providers who help us provide the Services. Service
providers help us with things like payment processing (i.e., banks, credit
bureaus, payment method providers), website hosting, data analysis, information
technology and related infrastructure, customer service, email delivery, and
auditing;

c. To Our
Users. We
share Data with Users (such as merchants and application providers) as
necessary to process payments or provide the Services. For example, we share
Data with Users about usage by their Customers through the applications built
on Hydrogen APIs and services;

d. To
Authorized Third Parties. We share data with parties directly authorized by a User
to receive Data, such as when a User authorizes a third party application
provider to access the Customer’s account. The use of Data by an authorized
third party is subject to the third party’s privacy policy;

e. To Third
Parties. We
will share Data with third parties in the event of any reorganization, merger,
sale, joint venture, assignment, transfer or other disposition of all or any
portion of our business, assets or stock (including in connection with any
bankruptcy or similar proceedings); and

f. Safety,
Legal Purposes and Law Enforcement. We use and disclose Data as we believe necessary: (i) under applicable law, or payment method rules; (ii) to
enforce our terms and conditions; (iii) to protect our rights, privacy, safety
or property, and/or that of our affiliates, You or others; and (iv) to respond
to requests from courts, law enforcement agencies, regulatory agencies, and
other public and government authorities, which may include authorities outside
Your country of residence.

5. Security.

We use reasonable organizational,
technical and administrative measures to protect Personal Data within our
organization. Unfortunately, no data transmission or storage system can be
guaranteed to be 100% secure. If You have reason to
believe that Your interaction with us is no longer secure (for example, if You
feel that the security of Your account has been compromised), please contact us immediately.

6. Advertising.

We may use third-party advertising
companies to serve advertisements regarding goods and services that may be of
interest to You when You access our websites, based on Data relating to Your
access to and use of our websites on any of Your devices, as well as Data
received from third parties. To do so, these companies may place or recognize a
unique cookie, or similar tracking technology, on Your
browser (including the use of pixel tags). They may also use these technologies,
along with data they collect about Your online use, to
recognize You across the devices You use, such as a mobile phone and a laptop,
and to make decisions about the advertisements You see. If You
would like more information about this practice, and to learn how to opt out of
behavioral advertising delivered by Network Advertising Initiative member
companies in desktop and mobile browsers on the particular device on which You
are accessing this Privacy Policy, please visit the Network Advertising Initative and Digital
Advertising Alliance.

You may download the AppChoices app to opt out in mobile apps. In order to understand and
improve the effectiveness of our advertising, we may also use web beacons,
cookies, and other technologies to identify the fact that You have visited our
website or seen one of our advertisements, and we may provide that Data to one
or more third party advertising networks. The Data we provide may include the
time and date of Your visit to our website, pages
viewed, links clicked and other information that does not disclose Your ‘real
world’ identity. Those advertising networks may recognize the web beacon or
cookie associated with Your visit to our website when You visit other websites
on which they serve advertising, and they may make decisions about the
advertisements You see based on it. We may choose to work with Google AdWords, Doubleclick, AdRoll or other advertising networks. Each of these
companies has its own privacy policy, which we encourage You
to review. For more information about advertising and tracking online, visit
the Network Advertising Initiative. This website allows consumers to “opt
out” of the behavioral advertising delivered by member companies. At present,
there is no industry standard for recognizing Do Not Track browser signals, so
we do not respond to them.

7. Choice and Access.

You have choices regarding our use and
disclosure of Your Personal Data:

a. Opting
out of receiving electronic communications from us. If You no
longer want to receive marketing-related emails from us on a going-forward
basis, You may opt-out via the unsubscribe link included in such emails. We
will try to comply with Your request(s) as soon as
reasonably practicable. Please note that if You
opt-out of receiving marketing-related emails from us, we may still send You
important administrative messages that are required to provide You with our
Services.

b. How You can access or change Your Personal Data. If You
would like to review, correct, or update Personal Data that You have previously
disclosed to us, You may do so by signing in to Your Hydrogen account or
by contacting us.

If emailing us Your
request, please make clear in the email what Personal Data You would like to
have changed. For Your protection, we may only implement requests with respect
to the Personal Data associated with the particular email address that You use to send us Your request, and we may need to verify
Your identity before implementing Your request. We will try to comply with Your request as soon as reasonably practicable.

8. Retention Period.

We will retain Personal Data for the
period necessary to fulfill the purposes outlined in this Privacy Policy unless
a longer retention period is required or permitted by law. Please note that we
have a variety of obligations to retain the Data that You provide to us,
including to ensure that transactions can be appropriately processed, to help
identify fraud, and to comply with anti-money laundering and other laws and
rules that apply to us and to our financial service providers. Accordingly,
even if You close Your Hydrogen Account, we will
retain certain Data to meet our obligations. There may also be residual Data
that will remain within our databases and other records, which will not be
removed.

9. Use of Services by Minors.

The Site is not directed at children
under the age of 13, and we request that they not provide Personal Data through
the Services.. We operate our websites in compliance
with the Children’s Online Privacy Protection Act and will not knowingly
collect or use personally identifiable information from anyone under 13.

10. Jurisdiction and Cross-Border
Transfer.

Our services are global and Data
(including Personal Data) may be stored and processed in any country where we
have operations or where we engage service providers, and we may transfer Data
to countries outside of Your country of residence, including the United States,
which may have data protection rules that are different from those of Your
country. However, we will take measures to ensure that any such transfers
comply with applicable data protection laws and that Your Data remains
protected to the standards described in this privacy policy. In certain
circumstances, courts, law enforcement agencies, regulatory agencies or
security authorities in those other countries may be entitled to access Your
Personal Data.

11. Privacy Shield.

If You are
located in the EEA or Switzerland, we attempt to comply with applicable laws to
provide an adequate level of data protection for the transfer of Personal Data.
Please note, Hydrogen is not yet certified under the EU-U.S. and the Swiss-U.S.
Privacy Shield Framework.

12. Hydrogen as a Data Processor.

We may collect, use and disclose certain
Personal Data about Customers when acting as the User’s service provider. Our
Users are responsible for making sure that the Customer’s privacy rights are
respected, including ensuring appropriate disclosures about third party data
collection and use. To the extent that we are acting as a User’s data
processor, we will process Personal Data in accordance with the terms of our
agreement with the User and the User’s lawful instructions.

13. Updates to this Privacy Policy and Notifications.

We may change this Privacy Policy. The
“Last updated” legend at the top of this Privacy Policy indicates when this
Privacy Policy was last revised. Any changes are effective when we post the
revised Privacy Policy on the Services.

We may provide You with disclosures and
alerts regarding the Privacy Policy or Personal Data collected by posting them
on our website and, if You are a User, by contacting You through your Hydrogen
Dashboard, email address and/or the physical address listed in Your Hydrogen
account. You agree that electronic disclosures and notices have the same
meaning and effect as if we had provided You with hard
copy disclosures. Disclosures and notices in relation to this Privacy Policy or
Personal Data shall be considered to be received by You within 24 hours of the
time they are posted to our website or, in the case of Users, sent to through
one of means listed in this paragraph.

14. Contact Us

If You have any
questions about this Privacy Policy, please contact us:

Because email communications are not
always secure, please do not include credit card or other sensitive Data (such
as racial or ethnic origin, political opinions, religion, health, or the like)
in Your emails to us.